Prod: October 6, 2023 (Updated October 31, 2023)
Platform implementation requirement:
- October 8, 2023 (UK only)
- December 1, 2023 (all other countries and jurisdictions except as noted below)
Actionable – Updates required for platforms
Breaking – If appropriate IP and other preventive measures are not made by the relevant dates, Platforms will have newly submitted participants located in certain countries declined by Zero Hash:
- United Kingdom (October 8, 2023): This is a reminder that to comply with the requirements of the Financial Conduct Authority (FCA), Platforms with existing participants in the United Kingdom will not be able to obtain new assets and will only be able to sell or withdraw existing assets. Additionally, Zero Hash will be unable to accept any new participants located in the United Kingdom.
- Updated List of Prohibited and Restricted Countries and Jurisdictions (December 1, 2023): Platforms with existing participants in newly listed countries or jurisdictions (other than the United Kingdom) will only be able to sell and withdraw existing assets as part of account closure. Zero Hash will not accept any new participants located in those newly listed countries and jurisdictions.
- The Netherlands (November 1, 2023): As of November 1, 2023, no new participants will be permitted from The Netherlands until Zero Hash has obtained the necessary licensing. Platforms with existing participants in the Netherlands will not be able to obtain new assets and will only be able to sell or withdraw existing assets.
- Effective Immediately: Zero Hash prohibits any customers located in the Gaza Strip.
Consistent with existing legal and regulatory requirements, Zero Hash has implemented prohibitions or restrictions on business activity with or in certain jurisdictions and countries. Zero Hash regularly reviews these prohibitions or restrictions to ensure compliance with OFAC and other relevant targeted financial sanctions as well as known AML/CFT/CFP risks.
Zero Hash is issuing this notice to inform Platforms and other stakeholders of its newly approved jurisdiction and country lists.
Future updates will occur at least annually (each January), but may be made more frequently on the basis of relevant changes in legal and regulatory requirements and applicable AML/CFT/CFP and related risks.
Updates to Prohibited and Restricted Countries, Jurisdictions, and Geographies
Subject to any further clarifications noted below, inclusion on one of the three Tiers of the Prohibited and Restricted Countries and Jurisdictions list means that Zero Hash will not do business with any entity or person located or formed in that geographical area (see notes for further explanation). This includes Platform, entity, or individual customers of Zero Hash LLC and Liquidity Services and its various affiliates (Zero Hash) and the natural person or non-natural person customers of any partner Platform.
Process for Unwinding Relationships Involving Newly Listed Countries/Jurisdictions. When a country or jurisdiction is newly listed, all existing Zero Hash direct or indirect business relationships will be revoked (immediately, if required by law or regulation). Natural person Platform participants in newly listed countries or jurisdictions will be permitted to withdraw/sell their cryptocurrency holdings (unless prohibited by law or regulation). All accounts will be disabled and closed.
Process for Restarting Relationships Involving Delisted Countries/Jurisdictions. When a country or jurisdiction is removed from the list (delisted), Zero Hash will begin to permit the establishment of new business relationships, including new natural person Platform participants. All such relationships will be established only after the application of the same Enhanced Due Diligence measures associated with a country or jurisdiction on the new Permitted Higher Risk Geographies list (see below).
Following the recent completion of its latest review, Zero Hash is updating its list of prohibited and restricted list to the following countries and jurisdictions or geographies (new listings are noted in parentheticals):
Prohibited (Tier 1)
Central African Republic
Democratic Republic of the Congo
Gaza Strip (added October 31, 2023)
Russian Occupied Regions of Ukraine (Crimea, Luhansk AKA LNR, Donetsk AKA DNR)1 (does not apply to territory controlled by the Government of Ukraine)
1 Russia-Ukraine War policy established March 2022.
Restricted (Tier 2)
Albania (Western Balkans) (new)
Bosnia and Herzegovina (Western Balkans)
Guineau Bisseau (new)
Kosovo (Western Balkans)
Montenegro (Western Balkans) (new)
North Macedonia (Western Balkans) (new)
Serbia (Western Balkans) (new)
Restricted (Tier 3)
People’s Republic of China (PRC)2
PRC Special Autonomous Region (SAR) Hong Kong3
The Netherlands5 (added October 31, 2023)
The United Kingdom4 (new)
2 Additional limitations related to the People's Republic of China: No Platform or business with more than 50% Chinese investors will be approved as a customer of Zero Hash.
3 As of June 1, 2023, all participant types from Hong Kong are blocked from onboarding and buying/acquiring assets. Existing participants are blocked from buying/acquiring assets but will be allowed to 1) sell/withdraw and 2) update their address if they are no longer located in Hong Kong.
4 As of October 8, 2023, no new customers will be permitted from the United Kingdom until Zero Hash has obtained the necessary licensing. Existing customers will be permitted to withdraw/sell existing assets.
5 As of November 1, 2023, no new customers will be permitted from The Netherlands until Zero Hash has obtained the necessary licensing. Existing customers will be permitted to withdraw/sell existing assets.
Permitted Higher Risk Geographies
Following the recent completion of its latest review, Zero Hash also has established a new list of Permitted Higher Risk Geographies for which Enhanced Due Diligence measures will be applied to all existing and new Platform, business, and individual customers of Zero Hash and all Platform participants (whether natural or non-natural persons).
The following countries and jurisdictions or geographies are included in this list, which is based upon the FATF’s “Grey List” and other public and proprietary assessments of AML/CFT/CFP, fraud, corruption, and other relevant risks6:
Bulgaria (added October 31, 2023)
United Arab Emirates
6 As of November 1, 2023, the Cayman Islands is no longer included on this list.
Platforms must ensure they adhere to Zero Hash’s requirements for existing participant accounts in prohibited or restricted countries and jurisdictions and ensure no new participants are onboarded with Zero Hash.
Platforms must ensure they are able to properly and consistently identify the location (both at time of onboarding and for transactions) of participants consistent with Zero Hash’s requirements.
For additional general information regarding the U.S. geographies that Zero Hash supports, please also refer to https://zerohash.zendesk.com/hc/en-us/articles/1500001390422-Permitted-Jurisdictions